0403_AnsonLF_wetlands_19990420

SMITH HELMS MULLISS & M®ORE, L. L. P
ATTORNEYS AT LAW
CHARL077E
GREENSBORO, NORTH CAROLINA
RALEtGH
POST OFFICE BOX 31247
POST OFFICE BOX 27626
CHARLOTTE, N. C. 28231
MAILING ADDRESS STREET Ab ORE SS
RALEIGH, N, C. R76111
TELEPHONE 704134
POST OFFICE BOX 2!927 SUITE 3400
TELEPHONE 515/75S-8700
GREEN.SBORO, N. C. 274Z0 300 NORTH GREENE STREET
FACSIMILE
FACSi MILE 704l334-9467 8467
GREE NSBORO, N. C. 2740I
E-MA1 ADDRESS
WRITER'S E-MAiL AD�RE55
WRITER'S DERECT DIAL
3361378-5421
TELEPHONE [phone]
WILL_BURTON�SHMM.COM.
FACSIMILE 33G/379-9558
April 20, 1999
VIA FEDERAL EXPRESS �
s`oC, 04,
Ms. Sherri CoghillOt
Division of Waste Management, Solid Waste Section North Carolina Carolina Department of Environment and Natural Resources
401 Oberlin Road, Suite 150 �� >
Raleigh, North Carolina 27611-7687 LjRe: Anson County Solid Waste Management Facility
Chambers Development of North Carolina, Inc. {Chambers)
Dear Sherri:
Pursuant to your request to Mona O'Bryant yesterday, please find enclosed;.a copy of
Chambers' 3anuary 12, 1999 :response to comments from the -united: States Department ofthe
Interior, Fish and Wildlife Service (FWS) and the North Carolina Wildlife Resources Commission
(NCWRC) regarding Chambers' application for a pennit to discharge fill material in connection.
with construction of the facility. As you will see, we have not included copies of the more lengthy
attachments to this response (such as the ELS Plans) that have been previously provided to the
Solid Waste Section.
We have also enclosed copies of Chambers' supplemental letters to FWS and NCWRC
dated April 12, 1999, These letters describe changes made to the draft Wetlands Miti anon
Plan based on conversations with the Corp of,igineers and a February 4, 1999 field visit to the
site by John Dorney of the North Carolina Division of Water Quality. A copy of the. revised
Stream and Wetland Mitigation Plan referenced. in these letters was forwarded to Jim Coffey
on April 8, 1999,
_FtiFs�
solid
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A'r
SPECIAL OLYM9PICS
W ® R L D 6 A K E i OFFICIAL L,AW FIRM FOR THE 1999 SPECIAL OLYMPICS WORLD GAMES
no a i N CA 9 a 11 k A

Ms. Sherri Coghill
April 20, 1999
Page 2
If you have any questions or need additional information, please give Mona (336-378-
5237) or me (336-378-5421) a call.
Sincerely,
SMITH HELMS MULLISS L MOORE, L.L.P.
William E. Burton III
Enclosures

CHAMBERS DEVELOPMENT
OF
NORTH CAROLINA, INC.
ALLIED WASTE SERVICES, INC.
April 12 1999
Mr. Owen Anderson
Piedmont Region Coordinator
North Carolina Wildlife Resources Commission
512 N. Salisbury Street
Raleigh, forth Carolina 27604-1188
Re. Corps Action ID No. 199800592
Chambers Development of North Carolina, Inc.
Anson County Solid Waste Management Facility
Bear Mr. Anderson:
Based on. conversations with the United States Army Corps of Engineers (the "Corps")
and'a February: 4 ,1999 field: visit to the Anson County site by. Mr. John Dorney of the North
Carolina Division of Water Quality, Chambers has modified the initial draft Wetland
1 itiwion Plan, (which was submitted to you -along with a.copy of our January.12, 1.999 letter to
the Corps) to include both stream, mitigation and`wetland mitigation. Accordingly, please find
enclosed a copy of the current Stream and Wetland Mitigation Plan dated March 1999 for the
above -referenced project prepared by A1mes & Associates, Inc.
As you may recall, construction of the proposed facility will result in the unavoidable fill
of 0.49 acres of jurisdictional wetlands including 1,084 feet of low -quality stream channels. To
compensate for these impacts, Chambers will conduct the on -site mitigation described below in
lieu of making payments into the Wetlands Restoration Fund or providing other forms of off site
mitigation:
Wetlands Miti ation. Chambers will compensate for wetlands impacted by construction
activities at no less than a 2:1 ratio. Thus, at least 0.98 acres of wetlands will be created. In
addition, the replacement wetlands will provide a more diverse habitat (vegetation and wildlife)
than that currently available.
Streams Mitigation. Chambers will restore a highly eroded, incised streambed with little
to no bottom substrate into a more natural configuration that will limit erosion and provide
increased habitat for wildlife and benthic macroinvertebrates. The stream mitigation will replace
1,084 linear feet of stream with approximately 1,285 linear feet of perennial stream (more than a
1:1 ratio).

Monitorin.. Chambers will conduct a five-year maintenance and monitoring period for
the stream and wetland mitigation areas.
In closing, Chambers believes that the .Stream and Wetland Mitigation _Plan provides
more than adequate compensation for the unavoidable impacts related to construction of the
facility. If you have any questions regarding the Stream and Wetland Mitigation plan, pleasc
contact me at [phone].

CHAMBERS DEVELOPMENT
OF
NORTH CAROLINA, INC.
ALLIED WASTE SERVICES, INC.
April 12, 1999
Mr. Brian P. Cole, .State Supervisor
UnAed_States Department ofthe 'Intenor
Fish and Wildlife Service
Asheville Field Office
160 Zillicoa Street
Asheville, North Carolina 28801
Re: Corps Action ID No. 199800592
Chambers Development of North Carolina, Inc.
Anson County Solid Waste Management Facility
Wetlands Permit Stream and Wetland Mitigation Plan
Dear Mr. Cole:
Based on conversations vv'ntii the United States Array Corps Engineers {
Co s of En meers the Corps
and a February 4, 1999 field visit to the Anson. County site by Mr. John Domey of the North
Carolina Division of Water Quality, Chambers has modified the initial draft. We 999 letter to
l i atiart ,Plrar� (,vbich saws submitted to you along with a copy of our January
the Corps) to include both stream mitigation and wetland mitigation. Accordingly, please find
enclosed a copy of the current Strea t sari T etianri litikqdmBq9 dated March 1999 for the
above -referenced project prepared by Acmes & Associates, Inc.
As you may recall, construction of the proposed facility will result in the unavoidable fill
o
of 0.49 acres of jurisdictional wetlands including 1,084 feet of low -quality ew d belowin
compensate for these impacts, Chambers will conduct the on -site mitigation
lieu of making payments into the Wetlands Restoration Fund or providing other forms of off -site
mitigation.
Wetlands Fitz ation. Chambers will compensate for wetlands impacted by construction
activities at no less than a 2:i ratio. Thus, at least 0.98 acres of wetlands will be created. In
addition, the replacement wetlands will provide a more diverse habitat (vegetation and wildlife)
than that currently available.
,S`tream mitigation. Chambers will restore a highly eroded, incised streambed with little
to no bottom substrate into a more natural configuration that will limit erosion and provide
n will replace
increased habitat for wildlife and benthic macroinvertebzates. The s� e stgat ream (more than a
1,084 linear feet of stream with approximately 1,285 linear feet of p
1:1 ratio).

monitoChambers will conduct a five-year maintenance and monitoring period for
the stream and wetland mitigation areas.
In closing, Chambers believes that the Stream and Wed nd IdW Edon Plan provides
more than adequate compensation for the unavoidable impacts related to construction of the
facility. If you have any questions regarding the Stream and Wetland Mitigation Plan, please
contact me at (803).547-3184...
Sincerely,
Brian N. Card, P.E.
Regional Engineer
Enclosure
cc : Mr -Allen Davis
Corps of Engineers, Wilmington Field Office
Post Office Box 1890
Wilmington, North Carolina 28402-1890
Mr. Dan Frisk, Refuge Manager (wlenel.)
Pee Dee National Wildlife Manager
United States Department of the Interior
Fish and Wildlife Service
Route 1, Box 92
Wadesboro, North Carolina 28170

OF
R,, iT"
January 12, 1999
IN&- Amen Davis
Corps of En&eers Wilmington Field Office
Post Office Box 1890
Wilmington, North Carolina 28402-1890
Rem Action ID No.199800592
Chambers Development of North Car®lin2, Inc.
Dear Mr. Davis:
Chambers Development of North Carolina, Inc. C Chambers") is writing in response to
Mr. Ernest W. Jahnke's December 22, 1998_ letter enclosing comments from the United States
Department of the Interior, Fish and `Wildlife Service �"�S") and the North Carolina Wild i%
esoearces Commission` `�VCWIZC" j. The FWS' artd NCWRC's' comments relate tb the Corps'
Public Notice.dated October 22, 1998 (the "Public Notice") regarding Chambers' application for
a permit to discharge fill. material at tine proposed Anson County Solid Waste Management
Facility (the "Site"). As requested; this letter responds to FWS' and NCWRC's comments. For
your conveniences we are forwarding copies of our responses with attachments directly to these
agencies. Although there is some overlap between the two responses, we have included complete
responses to each agency's comments to prevent any confusion.
As you evaluate FWS' and NC C's comments and our responses, please consider the
following points. First, many of the comments relate to the operation of the proposed facility
rather than the discharge of fill material into wetland areas. 'These types of comments are outside
the scope of the wetlands permitting process and do not require consideration by the Corps. As
discussed, interested parties such as FWS and NCWRC will have the opportunity to comment on
operational issues related to the proposed facility during the public comment period on the draft
Permit to Construct to be issued by the North Carolina Division of WasteManagement's Solid
Waste Section (the "Solid Taste Section"). In an attempt to expedite the overall permitting
process for the facility, we have responded to all of FWS' and NCWItC's comments. However,
our willingness to (ally respond does not mean that Chambers agrees that all of their comments
are entitled to the Carps' consideration during the wetlands permitting process.
Second, NCWRC's comments suggest that the wetlands permit not be issued until the
proposed facility and its potential impacts are discussed in a comprehensive environmental
document. Applicable laws and regulations do not require an environmental document for this
project because it does not involve public monies or public lands. Although no formal
January 12, 1999
Page I

environmental document has been prepared, Chambers has thoroughly evaluated the Site to
demonstrate that the proposed facility satisfies the detailed siting, design and operational
requirements in the Solid Waste Section's regulations. Much of the. data obtained. during this six -
year process is simfiar to that which would be in a formal environmental'document Again, to
expedite the permitting process, our responses include the information that NCWRC requested to
be addressed in an environmental document for the proposed facility even though many of these.
requests are outside the scope of the wetlands permitting process.
We believe that the. fallowing responses address the comments raised by F S and
NC RC regarding the fill`activities to be authorized by the Carps' wetlands permit: Chambers
sincerely appreciates the Corps' efforts to expedite the wetlands permittinggrocess. If you have
any questions or need additional information, please contact me at [phone].
Sincerely,
Mr. Brian P. Cole, State Supervisor (w/attachments)
United States Department afthe'Interior
Fish and Wildlife Service
Asheville Field Office
160 ZiWcoa Street
Asheville, North Carolina 28801
r. Owen Anderson (w/ attachments)
Piedmont Region Coordinator
North Carolina Wildlife Resources Commission
512 N. Salisbury Street
Raleigh, North Carolina 27604-1188
1\&. Dan Frisk refuge Manager (w/attachments)
Pee Dee National Wildlife Manager
U.S. Fish and Wildlife Service
Route 1, Box 92
Wadesboro, North Carolina 28170
January 12, 1999
page 2

Chambers' Response to United States Department of the Interior, Fish and lii if`e Service
Comment Letter Dated November 20,' 1998 (Log Nuer 4-2-99-013) (Attachment 1)
1. Potential Impacts.to Wetlands and eater i2ualift
The. Site includes approximately 1,20.0 acres west of Wadesboro, North Carolina located
adjacent to and north of Highway 74 The delineation conducted at the Site identified
approxirnateiy 310 acres of wetlands, consisting of floodplain (including forested and marsh
areas), intermittent stre,a.rn courses, headwater seeps, and excavated, ditched or drained wetlands.
Chambers proposes to place clean fill in approximately 1.6 acres of wetland areas (only 0.05% of
the total wetland acreage on the Site), including 1.1 acres of non -stream ' wetlands. The 3,730
linear feet identified in the Public Notice are low quality, drainage channels that historically have
been impacted by fanning and timbering activities. These storrnwater channels carry surface
water for a watershed of approximately 13 5 acres. Eased on the calculations in Attachment 2,
these channels should be classified as above -headwater according to 33 CFR 330.2(d). There will
be no landfill activities of any kind in the remainder of the wetland and upland areas in the bluffs
and floodplain areas of Brown Creel- and Pinch Gut Creels. A design drawing showing the final
landfill development is enclosed as Attachment 3.
The: proposed: facility is designed to avoid potential impacts to water quality. Chan, bens'
site -specific; Erosion and Sedimentati€ n (E&S) Plans have been approved by the Land Quality
Section of Do's Fayetteville R4onal office. " The approved Plans address the initial phase of
the proposed work north of the railroad' tracks (73 acres) and south of the.railroad tracks (14.3
acres). We have enclosed copies of theE&S Plans and approvals (Attachments 4; 5; 6 and 7):
Chambers will be required to obtain additional D approvals for any work beyond that
reflected in these initial plans and :approvals.
The Solid Waste Section's regulations require that the proposed facility include
storrnwater and sedimentation control measures sufficient to control surface water run-off and
rum -on generated from a 24-hour, 25-year storm event. 'to comply with those requirements,
stonnwater will be directed to sedimentation/retention basins allowing for a controlled discharge.
The design and maintenance protocol for the facility's storrnwater and sediment management
system are described in detail the E&S Plans and in Sections 2.1.10, 2.2.1.5, 4.3.7, 4.4.1.2,
4.4.2.3 and 4.4.3.2 and depicted on drags E-6, E-13 and E-14 of the Permit to Construct
Application. Copies of these sections and drawings are enclosed as Attachment 8. Leachate will
have no impact on water quality at the Site as it will be discharged to the local wastewater
treatment facility. To ensure that no unanticipated impacts to water quality occur, the Permit to
Construct Application also contains a Water Quaiity Monitoring Plan for the Site as required by
the Solid Waste Section regulations.
2. Pee Dee National Wildlife Refuge
Consistent with the Solid Waste Section's siting, design and operational requirements, the
facility is engineered to minimize impacts on the surrounding community and environment.
Access to the facility will be from existing Highway 74, a major thoroughfare with sufficient
January 12, 1999
Page 3

capacity to handle truck traffic to the landfill. No off -site infrastructure will be constructed in
connection with the facility. With respect to nuisance wildlife, the Solid Waste Section's
regulations require the facility to control and/or prevent sin -site populations of disease vectors
and "other" animals using techniques appropriate for the protection of human health and the
environment. Controls at the Si$e w;11 include daily cover manageme t, litter control and
adequate fencing. These procedures are; described in Sections 4 3.4.4 and 4.41.5, of the Permit to
Construct Application (Attachment'9).
.3. Sufficiency of Weilan& Mitigation: :
e have enclosed a copy of the draft Wetlands Mstigation Plan, dated May 1998,
prepared by Alrnes & Associates, Inc. (the "Mitigation Plan")(Attachment 10). As Section 4.0
of the litigation Flan indicates,. the proposed. project will impact 1.1 acres of wetlands and 3,730
linear feet (which equates to approximately 0. 5 acres) of prim y low quality, d wage, channels
that historically have been affected by human activities associated with farm and timbering
activities. These channels carry surface water during periods of, and subsequent to, wet weather.
Based on the criteria in North Carolina's New Wetland Rules: Supplemental infcrrnation - Field.
location of streams., ditches and ponding„ dated February 10, 1997 (the "Guidance"), most of the
imp acted areas are classified as.:.storznwater.. channels ratherthan .inteamittent streams. In a March .. .
12, 1998 'Mernorandurn documeritin� his site visit (Attachment is y� den Averitte'ofthe North
Carolina Division of Water Quality's (" 1, WQ") Fayetteville Regional �ffice questioned whether
any of these channels should be classifiedas intermittent streanns and concluded that the
stoirr water channels provide very limited water quality fozic*,ioi .
As. described in the Mitigation Plan; Chamberswill. create.3.2 acres. of high -quality,
permanently inundated wetlands to mitigate for the fill of 1.6 acres of marginally functional,
seasonally saturated wetlands and wet weather channels on the Site. Based on the specific
conditions at the Site and observations of DWQ staff, in -kind mitigation of the channels would
not afford any discernible benefits. Mather, the proposed mitigation area will afford a greater
degree of wetland functions and increased wildlife habitat, will provide better protection of water
duality at the Site and will better satisfy the designated wetland uses outlined in state 'regulations
than other nutigation alternatives. As FWS suggested, the Mitigation Plan will be modified -to
provide for monitoring of the mitigation site for fide years.
4. Reguest for Conservation Easement
Although there is no legal requirement to impose a conservation easement on any portion
of the Site, Chambers is willing to discuss the passibility of granting a conservation easement for
areas along Pinch Gut Creels and Brown Creels and/or the wetlands mitigation site. These
discussions, however, should not delay issuance of the wetlands permit. Significant protections
will already exist since much of the area that FS requested to be covered by a conservation
easement is located in the buffer areas on the Site and no landfill activities of any kind will take
place in the remaining floodplains.
January 12, 1999
Page 4

Chambers' Respomve to North, Carolina Mildlife Resources Commission 1.5 Comment
Memorandum dated November 20,1998 (Attachment 12)
1. Descri tio®n of Fish and Wildlife Resources/Federally or State. Designated
Threatened, Endangered or Special Co.nees n Species,. .
As part of the Site Suitability Study required by.the Solid Waste Section's regulations,
Chambers retained Carlow & Associates to prepare a Wetlands Delineation and Protected
Species Survey of a Proposed lie 'onai Landfill Site Anson CougV, North Carolina (the
"Wetlands Delineation and Protected Species Survey")(Attachment 13). The Wetlands
Delineation -and Protected Species Survey provides detailed descriptions of the ecological
communities on the Site and concludes that the project will not impact any federal or state
designated threatened; endangered orspe ialconcern species. As documented in a letter dated
December 16, 1996.(Attachment 14), the N rth Carolina. Division of Parks & Recreatip agrees ...
with the Wetlands Delineation and Protected' Species, Survey's," findings that there are unlikely to
be impacts on any federal or state listed species of plants and animals" and that "the area to be
occupied by the landfill itself has little significance as a natural area,." As documented in two
letters, the United States Fish and Wildlife Service has concluded that the project will have no
effect on listed species (Attachments 1 and 15).
2. OwnerAip ®f Hi h Quality Habitat Alon-Browrn Creek
Chambers owns the referenced areas along the eastern portion of Brown. Creek and the
western portion of Pinch Gut Creek. The high quality wetlands adjacent.to the creeks will be
included in the undeveloped buffer areas and no landfill activities of any. kind will take place; in
the remaining floodplains. A design draining shoring the final landfill development is enclosed
as Attachment 3.
Although there is no legal requirement to impose a conservation easement on any portion
Of the Site, Chambers is willing to discuss the possibility of granting 4.conservation easement for
areas along Pinch Gut Creek and Brown Creek and/or the wetlands mitigation site.. 'These
discussions, however, should not delay issuance of the wetlands permit. Significant protections
already will be in place since rnuch of the area: that NCWRC requested to be covered by a
conservation easement is located in the buffer areas on the Site and no landfill aedvities of any
kind vain take place in the remaining floodplains.
3. Wetlands Mitization Plan
We have enclosed a copy of the draft Wetlands NEti ation Plart dated May 1998,
prepared by Almes & Associates, Inc. (the "mitigation Plan") as Attachment 10. Section 6.0 of
the NEtigation Plan provides a detailed description of the proposed mitigation site. The
Wetlands Delineation and Protected Species Survey (Attachment 13) also discusses the wetland
cornumunities on the Site.
January 12, 1999
Page 5

4. Imnact on- Fee Dee Wildlife Refuge
Consistent.with the Solid Waste Section's siting, design end: operational requirements, the
facility is engineered to minimize impacts on the surrounding community a.nd environment
Access to the facility will be from existing Tfighway 74, a major thoroughfare with sufficient.
capacity to handle truck traffic to the landfill. No off -site infrastructure will be constructed in
connection with the facility. With respect to. nuisance wildlife, the Solid. Waste Section's
regulations require the facility to -.control and/or prevent on -site populations of diseasei vectors
and "other." animals using techniques appropriate for the protection of human health and the
environment. Controls at the Site will include daily cover management, litter control and
adequate fencing. These procedures are described<in Sections 4 3 4,4.and 4A4 5 of the Permit to.
Construct Application_ (Attachment 9):
Section 4.0 of the Mitigation Plan provides a detailed description of the°.plant:species in
the wetland areas to be impacted. by the discharge of fill materials.
°6. Stream Mitigation
As Section 4:0 of the Ntigation Plan indicates;, the proposed project will impact 1.1 acres
of wetlands and 373 Q linear feet'(which equates to approximately 0.5 acres) of primarily low
quality, drainage channels that historically have been affected by human activitiesassociated,with.
farm. and timbering activities. ' These channels carry surface water during periods of and
subsequent to, wet weather. Based on the criteria in North Carolina's New Wetland Rules:
Sul2plemental information -Field location of streams ditches and pondin dated February 10,
1997 (the "Guidance"), most of the impacted areas should be classified' as stormwater channels
rather than intermittent streams. In a March 12, 1998 memora_ndum documenting his site visit
(Attachment 11), Ken Averitte of the North Carolina Division of'Water ` Quality's ("i Wq ):
Fayetteville Regional Office questioned whether any of these channels should be classified as
intermittent streams and concluded that the stonnwater channels provide very limited water
quality functions.
As described in the Mitigation Plan; Chambers will create 3.2 acres of high -quality,
permanently inundated wetlands to mitigate for the fill of 1.6 acres of marginally functional,
seasonally saturated wetlands and wet weather channels on the Site. Based on the specific
conditions at the Site and observations of DWQ staff in -land mitigation of the channels would
not afford any discernible benefits. We believe that the proposed mitigation area will afford a
greater degree of wetland functions, will provide better protection of water quality at the Site
and will better satisfy the designated wetland uses outlined in state regulations than other
mitigation alternatives. In addition the Mitigation Plan will be modified to provide for
monitoring of the mitigation site for five years.
Jununry 12, 1999
Page 6

7. Erosion and Sedimentation Control
Chambers' site -specific Erosion and Sedimentation (E&.S)>Plans have been apprbve.d.by
the Land Quality Section ofDENR's Fayetteville Regional office. The approved Plans address
the initial phase of proposed work north. of the railroad tracks (73 acres) and south of the.
railroad tracks (14.3 acres). We have enclosed copies. ofthe.E&iS Plans and approvals
(Attachments 4, 51.6 and 7) Chambers,w .be reguired`to obtain'a: itionalDENR'approvals
for any work beyond that reflected in these initial plans and approvals:
The Solid Waste Section's regulations require that the proposed facility include
stormwater and sedimentation control measures sufficient to control surface water run -tiff and
run-on generated from a 24-hour, 25-year storm event. To comply with those requirements,
stornawater will be directed to sedimentation/retention basins allowing for a controlled discharge.
The design and maintenance protocol for the facility's stormwater and sediment management
system are described in detail the E&zS Plans and in Sections 2.1.10, 2.2.1.5, 4.3.7, 4.4.2.3 and
4.4.12. and depicted on drawings -E 6, E-13 and E14 of the.Permit to: Construct Application.
Copies of these sections and drawings are enclosed as Attachment V.
3. Leachate and Storrnwater Management
Leachate from the facility will be collected and pumped directly to the sewer system for
proper treatment and disposal at the Anson County's wastewater treatment facility. The
facility's leachate collection system is described in detail in Section 1.2.4 of the Permit to
Construct. Application. A copy of this section is enclosed as Attachment 16.
Stormwater management is described in Response 47.
9. Upland Wildlife Habitat
Section 3.3.1 of the Wetlands Delineation and Protected Species Survey (Attachment 13)
provides a detailed description of the upland communities on the Site. Figure 2 in the Wettlands
Delineation and Protected Species Survey depicts the uplands communities on the Site.
10. Impact on Wildlife Habitats
The activities to be authorized by the wetlands permit will only impact 1.6 acres
(approximately 0.5%) of approximately 310 acres of wetland communities on the Site. The
remainder of the project is located in a loblolly pine plantation area that has been harvested and
planted since 1967. As the Wetlands Delineation and Protected Species Survey notes, there is
very little natural or undisturbed upland habitat on the Site. The North Carolina Division of
_- January 12, 1999
Page 7

Parks & Recreation agrees that "the area to be occupied by the landfill itself has little significance
as a natural area." See Attachment 14,
11. Reduction of Impacts
As described in the Mitigation Plan, Chambers will create 3.2 acres of new high quality
wetlands on the Site. This compensates for the wetlands to be impacted by the fill activities at a
2:1 ratio. The only high quality habitat areas on the Site (other wetland areas, bluffs and ravines
along Brown Creek and Pinch (gut Creek) will be included in the undeveloped buffer areas. In.a
letter dated Septeanber .1..1998 we provided inf®rdiatidn to the .Cbrps on the lack of practicable
alternatives to placing fill-in the wetland areas (Attachment 17). Based on this information, the
Corps concluded in the Public Notice that "the proposed project appears to be the least
environmentally damaging practicable alternative."
5anuary 12, 1999
page 8

Parks & Recreation agrees that "the area to be occupied by the landfill itself has little significance
as a natural area." See Attachment .14.
11. Reduction of ll lRacts
As described in the 1M igation flan, Chambers will create 3.2 acres of new high quality
wetlands on the Site. This connipegasates for the wetlands to be irnpacted by the fill act."w'-des at a
2:1 ratio. The only high duality habitat areas on the Site (ether wetland areas, blues and ravines
along Brown Creek and Pinch Gat Creek) will be included in the undeveloped buffer areas. In a
letter dated September 1, 1998, we provided information to the Corps on the lack of practicable
alternatives to placing £ill in the wetland areas (Attachment 17).. used on this information,. the
Corps concluded .in the Public Notice that. "the proposed, project appears to..bethe least'
environmentally damaging 'practicable alternative."
January 12, 1999
Page 8

V
United States Department of the Interior R Eu` E I V E D
FISH LIFE SERVICE
Asheville Feld Office
160 Zillicoa Su-eet
Asheville. North Carolina 28801
November 20, 1998
Colonel Terry R: Youngbluth
Wilmington District Engineer.
U.S. Anny Corps of Engineers
P.C. Box 1890
Wilmington, North Celina 28402-1890
Dear Colonel Youngbluti--
0 V 23 199a
REGIJL AT©hv
WILIMINGTON riE'.D3 01F�!(,?-
Subject: Permit applic.-Won by Chamb= Development of North Carolina, incorporated, to fill
0.49 acre of wetlands and 3,730 linear feet of steams west of Wadesboro in Anson
Co tt', N0TTh Carolina (Action ID -No. 199800592)
T-bis is the response df the €d.S. F`ish and WildfifcServlce (Servic:6) and the Departm�mf'of the
Interior to the public notice dated October 22,1998, for a permit application submitted by
ChambersDevelopment of Notth Carolina., IncorporaVA, to impact waters of the United States in
conjunction with the construction of a new municipal solid waste landfall `t^of Wadesb6ro"in
Anson County, north Carofl a. This report is based on a site visit and a review of the public
notice and is submitted in accordancewith the provisions of the Fish and Wildlife Coordination
Act, as amended (16 U:S.C. 661-667e), and the Endangered Species Act of 1973, as amended
(16 U.S.C. 1531-1543) (Act).
We are concerned about the quantity of wetlands and strews impacted and the potential effects
to water quality from the proposed landfill. The Brown Creek subbasin received a "fair"

bioclassiftcation Barn the North Carolina Division of Water Quality. Nonpoint-source pollution
is a current problem in the brown Creek sdbbasin. We are also increasingly concerned .about the
loss and fragmentation of upland habitat due to projects such as this; we offer here some
rneasures to minimize these adverse effects but expect we will seek mitigation for impacts to
upland habitat for fixture projects.
I at l Cola„ id-u. The proposed project is adjacent to, and upstream of; several excellent
examples of natural community types that are dependent on natural hydrologic regimes and are
not common in North Carolina. These natural communities are piedmont levee forest (vegetative
assemblages on seasonally or intermittently flooded natural levees and point bar deposits on
flood plaints), piedmont bottomland. forest (vegetative assemblages on hood plain ridges and
terraces adjacent to riven char nels), piedmont swarup forest (vegetative assemblages on
back -swamp deposits and sloughs), and flood plain pool (depressions in abandoned river
channels on flood plaints holding water much or all of the year). Natural communities like these
provide habitat for a variety of annuals, such as game species (white-tailed deer, raccoon,
cottontail rabbit, gray squirrel); Neotropical migratory birds (Kentucky warbler, wainson's
warbler, downy woodpecker, towhee, Carolina wmn, mockingbird, white -throated sparrow,
common grackle, blue jay); and numerous butterflies, amphibians (frogs, salamanders), and
fishes (sunfishes, darters, rosyside dace).
unity to: Feee Dee Nafigngl Wildlife Refu �. The proposed landfill is close to the Fee Dee
National Wildlife Refiige (Refuge). Situated on the bauks of the Fee Dee River in the southern
portion. of the lbwer pie€irt Gnt, the Refuge"s 8,443. ace range from bottomland hardwood forest
to land sine: diverse Idlife; habitat; also includes abandoned fields, naturally reforested
areas, cultivated land, and over a dozen ponds and creeks The primary objectives of the Refuge:
to provide wintering habitat for Canada geese and -ducks, provide sanebimy for wood ducks,
protect and m& ce habitat for the endangered led -cockaded woodpecker, and provide
interpretation and recreational opport mities for the public. The Refuge attracts thousands of
waterfowl annually, including blue wing teal, mallards, ring neck ducks, Canada geese, and snow,
geese, and provides important habitat for the American woodcock, snipe, and red -cockaded
woodpecker. The endangered red -cockaded woodpecker is a ycar-round resident, and the bald
eagle and peregrine falcon (both threatened) are transient visitors. Twenty-eight species of
mammals can be found, including beaver, bobcat, fox, white-tailed deer, raccoon, opossum,
squirrel, rabbit, and pine vole. The Refuge bird list contains over 170 species, including
bobwhite quail, mourning dove, Canada geese, and prothonotary warblers. There are also over
56 reptiles and amphibians, including Fowler's toad, eastern musk turtle, six -line racertinner, and
rough green snake.
Based on the proximity of the proposed landfill to the Refuge, we are quite concer-r,ed about the
indirect effects to the Refuge from the issuance of this permit. We are particularly concemedd
about the potential impacts of this proposed landfill on migratory birds and mobile carnivores.
Nonnative or gregarious flocking birds are often attracted to uncovered or windblown waste at
landfill sites. Will flocking sea gulls be attracted to the landfill? We are also quite concerned
2

about the potential for carnivores to be attracted to the site. We believe that daily ever
management and fencing may address some of these wildlife issues. Are detailed -operational
plans available? What type of fencing will be installed at the proposed landfill? What will be
the fence monitoring/repair schedule? These questions and issues need to be addressed in the
environmental document developed for this permit.
R=o mendations. We are providing thel following general recommendations:: for incorporation
into the project plans to Mlinj=i e the impacts of this project on fish and wildlife:
1. All storm -water outlets should drain through a vegetated upland area prior to
reaching any stream or wetland areas ; Sufficient retention designs llcallow
f®r the slow discharge of stoma water, attenuafing the potential adverse effects
of storm -water surges, thermal spikes, sediment; nutrient; and chemical
discharges.
We�iti ag_t�- Plans for the proposed wetland mitigation at the tributary to gown Creek
should be submitted for our review immediately, because we have many doubts about its
feasibility. What type of wetland will be emated? Will the wetlandxely on groundwater or
over -bank flooding for hydrology? How will the: wetland tunction relative to the piedmont
semipermanent impoundment downslope? Will the railroad grad: affect hydrology at the
mitigation site? We recommend preservation of the remainder of wetlands on the tract thmugh a
permanent, registered easement.
treaaraMitigation. Since we have been disappointed with recent compensatory stream
mitigation efforts for other projects, we request the opportunity to review all stream channel
relocation/restoration designs and field delineations prior to construction and prior to the
diversion of water. We believe a successful stream mitigation playa will need to first describe
what the natural channel is relative to the principles of fluvial geomorphology as well as what
functional relationships it will have relative to upstream and downstream aquatic communities.
3

'Since the watershed area of the proposed mitigation site is inadequate to support perennial stream.
rchannels, we do not agree that the creationirestoration of stream channels here will be
commensurate with the proposed impacts. We can assist in identification of more appropriate
stream channel segments for restoration within. the Brown Creek watershed area. We agree that a
2e l ratio of mitigation to impacts is appropriate for the proposed strew impacts. We
recommend the following elements be included in any strearn mitigation plan for this project:
1. Riparian vegetation should' include native goody species, such as alder (Alnus
spp.) and black willow, as well as gl?undinaHa, sedges, grasses, and rushes.
E--odc -vegetation should be screened from any plant material. Large wood
species will provide thermal cover as well as deep bank -stabilize groot Y
systems along any const mcted,br reconstrnctcd sty channel.
I Stream chapel construction and vegetation eeablishrnent should. take place
Prior to the diversion of water into the new channel- Sequential construction of
segments and temporary pipe diversions can be utilized to ensure channel
stability. We would like to have an Opportunity toinspect stream segments for
stability prior to the water diversion.
3. Stream chapel design should mimic slope, rife a sla pool slope, valley.
slope, pe>
slpe,::mnde8 erne try, smuosrty, cross -sectional dimensions, entrenchment
ratio, ,bed: a1 (pebble-munt), and b Ul: d harge of a nearby
reference reach of a stable stream of the same classification' (Rosgen 1996).
Bank -fail dimensions should be generated based on, ,those -of an appropriate
reference reach and/or the latest discharge(charmel dimension relationship
developed: for the piedmont (vie can suPp Y l a. .py of these. es if needed): .
e would like to review the final of the stream channel restoration and
relocations.
4. Monitoring should continue —tor at least 5 years following channel construction.
ua.l reports should be submitted to the resource agencies. Resource
agencies should be notified of problems with success or function of the stream
mitigation within 30 days of detection.
5. An appropriate regional conservation Organization should hold title to the deed
restrictions on the mitigation site. The title to the conservation easement
should be conveyed along with an endowrnent for future monitoring,
management, and any contingencies to ensure a perpetual net increase in
stream channel function in the project area. Since North Carolina law
currently requires the filing of conservation easements every 30 years, the
endowment should make provisions for the required legal filing.
4

IN
6. The remaining tributaries to Pinch Cut Creek and Brown Creek within the property
should be set aside in a permanent conservation easement.
7. We recommend enhancement of the. riparianbutler on the West side cif Brawn .
Creek with bdtternland'hardw ocid`species: Plantings should extend at least
100 feet from the strearn.
8. The final mitigation plan should provide details relative to what measures will be
taken to contrail watershed. conditions and prevent sediment pollution and increased
water discharge that would potentially negate efforts at the stream mitigation site(s).
°he latest draft "Guidelines for stream relocation and restoration in North Carolina," by the
'North Carolina Wildlife Resources Commission, is a ood D :ide to proper sLrea_*ra restoration d
relocation work. 4L7
Based on a review of our records andour knowledge of the site, we concur with the
ennination that there will be no effect to listed' species. Therefore, we believe the
requirements under Section 7 of the Act are fulfilled. However, obligations under Section 7 of
the Act must be reconsidered if. (1) new inforinationreveals impacts of this identified action
may affect, listed species or critical habitat in a manner not previously considered., (2) this
act.0 is S.. sequentlY. modified in -a mmmer thk was not considered: in this review; or (3) a new:
species islisted or; critical:habitat isActertrniriedthat may, bi. affected by the -identified action.`
Please do not hesitate to contact Mr. mark Cantrell of our staf°at. 2S/25&39397 Ext. 227, ifyou
have by questionsregaz=g our comments. We lam assigned:our La Number 4-2-99-013 to
this project; pleaserefes:toit in. all `future correspondence -directed to us concerning.this his matter.
Sincerely,
Brian P. Cole
State Supervisor
cc:
Refuge Manager, Pee Dee National Wildlife Refuge, U.S. Fish and Wildlife Service, Route 1,
Box 92, Wadesboro, NC 28170
Mr. Allen Davis, U.S. may Corps of Engineers, Wihnington District, P.O. Box 1890,
Wilmington, NC 2M2-1890
Mr. Owen Anderson, North Carolina Wildlife Resources Commission, 1142 1-85 Service Road,
Creedmoor, NC 27522
Mr. John Dorsey, North Carolina Department of Environment and Natural Resources, Division
of dater Quality, 4401 Reedy Creel' Drive, Raleigh, NC 27607
5

2.2.1.5 Stormwater System DcsiW
To design the proposed stormwater control and conveyance stnictures and jc)
evaluate perfommnee of the proposed sedirnent basin for Phase I development (Basin No. 1),
10, 25, and 100-year frequency stormwater nmoff was routed tbrough die proposed systenL
I'lie =-;dyses was perfomied by the procedures and couputer prograrns aR-55 and TR-20)
developed by USDA Soil Conservation Services. The results of the analyses (attached) indicate
that the proposed stomTwater controi and conveyance suucft= and Sediment Basin No. I will
safely and effectively contain the design stoniL The calculation also ind6te, that the proposed
ear storage �apacity:and the outlet: discharge capacity.for Basin No. I.am adequate to passJO&y
frequency peak runoff with adequate freeboard.
As required by the North Carolina Sedimentation Pollution Control Law, Chambers
is in the process of preparing a site -specific Erosion and Sedimrnt Control Plan- Tl:s pian will
. .... .... . .
include additional detailod ha y ogic aiid *iiiilic desu: h, *dpbsed-cofitro M=
and will be- submitted. to the NorthCarofina Sedimniadon Control Commmion. for approval
and issuance of a'�Cerdficate of PM';kpprovar,. Land disturbance activities wiii not be initiated
prior to the issuance of the 'V-ertificate of Plan ApprovaT.
3. Geo� �thetic � Ives` o Guidance for Hazardous Waste Landfill Cells and Surfacz
j=undments, by Richardson and Koerner.
4. Driscopipe System Design ManuaL
1(). FLOWMASTEP, MicrocorrTuter Program by Haested Methods.
2-22

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STORMWATER MANAGEMENT
SYSTEM DETAILS
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Nc No.

'1-zu-�a ® l d a �c 9 f l4 :;�t 4044- uz�At;L- csg, brancn;o 2
North Fly W• b eion
51 Z N_ Salisbury Strezt. Raleigh, North Cwthm 27 11 , 919M3-3391
Charles R. Fullwood,
E.MORAINli$UM
TO:
FROM
D T L;
SUB TEC` :
98/'1
Staff
.. a 1: the Wildlife Rmurm Commission have coma . ,r a review >t
f the
au�jtct notice. tc. assess inipacu on rand fishery :fir. o.. n the k =; Ow commentsare
ywvj&d fii actx1rda= with provisions of the Clean Water Art of 1977 (�3 U.S.C. 466 at wq.), and
The applicant prapm to discharge fill matedW into 0.49 acre of wetlands and wa of the
Urftc.d States, snd uding 3.7.10 linear fect ofludsdicdonal perennial and intcrrninent atrearns for
consi suction c:f <a solid waste landfill. The site is located up slope of Brost Creek and Pinch Gut
Creek.
. The wetlands to be impacted we chameterized as headwater fore= and s=blshrub
wetiEnds. The proposed mixi8ation 1s for wWand crution at do fmr 0.49 acre of wetland fill,
The proposed i.Titigation .Bite: is located Aa=t to Brown Creek adjacent to twisting wethmds.
There arc five natt t comet ides recorded in the Nawral Heritage databme for the area
aict:E Brown (:r:ek an cr aad`;acent to the landfill property. It is trot clear from the Public Notice if
this arTlIcant ox--ens this property along Brown CrceL The five community types known from the
f ocdplapin and sxtT -, ,,)f bl row n Creek = Piedmont Mountain Swamp Fcregt� Piedmont Mountuin
Send arl Impctzndme nt, Flcodplain fool, Piedmont /Mountaiafl Bottornland and.
Piedriont/Mmz win LoVoc F ore -it.

`1 518 UUS-i USACE-Rag. Branch;, �
a
Solid Taste La-Afill 2
�4oat Co,
The Pm Dee "il(iliie lZefte is located Vproximeftiy five - es d�Wngtream and provides
vacio,.L,,habitat -�s that am, regionally im-portant to a divem assmbla ge of game and nongame
fsh and wild,'.1, spccics. Tie refuge is CSPCCWIY iMPOrtalit to migngou waterfowl wd songbirds.
Add:.1�ona:1y, 'th.. refuge provides breeding habi t for the federally and state endasibered red-
ckadcd wc? Apecker. There are also M=rds of bald eagle and peregrine falcon using the refUge.
Add: ticrmly, Lbe refuge lgrcavides habitat for num=us other species of plaim and ands fmm
vark,us taaa. Bt-sides being important biology, y, the ?cc Doe Refuge provides significant
=r0tional opportuDides. which include hunting, fishing and wildlife observation. Therefore, the
refill d is regi-In_ally important for talmism
We avevcry cono:med about the Miting Of this limdfill along Brown Creek 4acent to
thai :, abc s ig pia .carat fish and w0dlife habitat value. We believe this project has the potential to
ar Ix1 advent'` a regions :'ly important natural rnource and tourist site.
The ink:imati.oi~ included with the Public Notice is not sufficient for our staff to detemine if
weIand impair— have be n mini or what se dary adverse impacts will result from the
ins'€tr cC oi' .s i)61=iL IVre=Mm=dpamits not be iwucd until the project and issues are
.dis,,.ti-.cumac�mPf,tiler-3i-treenviromnentaidocun=t Ste and fedcrW resource agencies and the .
F p
pUb c.:should ILWC an 0p'1orturndty to review the =vimumcnW. doctri�crat amid �. rovide iia ut.
6 hffv;., thc;folloMng eons =d requests to assist with preparation
0f gar :nvircmiirw-MaJ d rna nt.
44 Provide a discussion of the impa s the vperaticn of this landfill will have on the peeDee
Wildli-re refuge and area fish and wildlife. This should include issues such as increase truck
uric, c cdditional intirast t (0.g.. new or itnprovod roads and ()thc:r fsc:aiities'JS oriated
wish hinAdl upunition), nuisance wildlife (eeg, sew gulls) and effects oil other non -nuisance
specie which could. be attracted to the landfill.

anon .ti:crbc� 9039-0 USACE-Rag. Branch;# 4
Solid Waste Lmidfill 3 November 20, 1999
5. Providc a clariticzai::erg of the plants ies with,the perm al and: aaatcrariiiiezat
stsca€ yis to he impacied.
6. Providd icaibrmau-ln on how the 3,730 feet of strmm wjU be naitla ted< WC rc� cat that a.
effort lX- made to :1mate stream. Mitigation si in the lower Yakdin-Pee Dec Basin of North
Qrrulim, especially the Brown C 's€ab n. toration reaches should be
Similar in cha.t~actenbiacs to naturaL stable refemce reaches. we recommend the methods of
Rosgen l 996) be €oliowcd for sa=m restoration.
7. trOvidc a discussiOn Of vvhat M _ will be put in place to prevent erosion and
sediMC'n.t.1dOr-- TO sudrace watcrz and haw thcae device will be maintained. Include the
specifiC width of buffers to be lei along and wetlands.
FIrcovida a discussion of how la=hste fmm tho joufflil will be ftated and how swrrnwater
from tfic site will be managed.
9, F-rovida a description and a cover rap showing &CMAge ofupland wildlife habitat of the
project site includiRg, those areas along Brown Creek.
10. i wss the , tcnt to Whach the pwject will result in loss, deg
radation or i'ragrraentatien of
wildfiX.; laabiMt(wedands and`vpl. s)f. Lmpactq.for altemative. sit :or,desi should be
1 ]. Dimes% any niewures proposed to avoid car t . a of the project or to .agate
unavoUable hnbitit losses. The numag=ent of ft buff= is especially relevant.
'9"e-apPrtciate the OPPOftunitY to review dlis
't _zPpficatiom I f -you sped er..................................... .
sis"iMea or asddiduna l inior7nadon, piesw contW me at [phone].
[.1te-uxc Mcd:
Rosgrer., Dave. i c es. applied River 1V M00108Y. WfldJ=d IiYdMIOV, F%rosa Springs. 843 pp.
ec: Mark (.�,tntrell, Biologist, USFWS Asheville
Dan Fri.:k, Ref ugt: M.'Mm9er, USFWS, Pee Dee XWR
john l arkcr, Coastal Management
John Do:mey, W-t sr.,d Scientist, Division of Water Quality
Melba k1reGee, Enviinnmerntal Coordinator, ®LiA
Steve I1-- U, Zpolc)gis,:, Natural Heritage Progmm

State of North Carolina
Departrrlent of Environment,
Health and Natural Resources
Division of Pcrks & Recreation
James S. Hunt, Jr., Governor
Jonathan 8, Howes, Secretory
Dr. Philip K. McKnelly, Director
December 16, 1996
BarbaraA. Garrow
Garaow & Associates, Inc.
3772 Pleasantdale Road, Suite 200
Atlanta, GA 30340-4214
Re: Anson County Landfall.
Dear Ms. Ga,rrow:
The Division l°ias reviewed the proposed landfall project for passible impacts to significant
natural areas, rare species, _and recreational. fac areas. "We cornmend, the preparers of the
survey report for their thoroughness and concur with. the findings that there are unlikely to be
hnpacts on any fed --al or state listed speci= of plants and anirr-,als. We also agree Lat the area
to be occupied by the landfill. itself has little significance as a natural area.
swearer, we sham; the concerns expressed by the Fish. and Wildlife Service (Gabatt, 7131/92)
that there could be: i A .io the Pee Dee National Wildlife Refuge if water guy in Browns
Creek and Pinch Cut CrL--k is not protected. We concur with the r =mrnendations made by
the Spice, as well as in the survey report, that bath the steep slopes and bottom -lands along
the two creeks be left intact, These areas have also been identified by the Natural Heritage
rograir� as part of the Brciwns Creels Swamp Priority Natural Area. As mitigation for the
possiale impacts of the landfill operations, we request that these areas be considered for either
registration as a. Natural Heritage Area or dedication as a State Nature Preserve.
Sincerely
Stephen P. Hall, Environmental Review Specialist
cc: Mr. Jose Urr-uda, USA Waste Services
P.O. Sox 27687, Raleigh, North Carolina 2761 T-7687 Teiephone 919-733-418 T FAX [phone]
An Equal Opportunity Affirmative Action Fmpicyer recycled/ 10% post -consumer paper

AUG 031992
Rals:ate Fieid Office
Mr. Gregory C. Cakander ja AA
Chambers Development Co.
3200 Highlands Parkway
Suite 400
Smyrna, Georgia 30082
Dear Mr. Cakan er
The U.S. Fish and Wildlife Sar vicz (5ery ice) :aas completed :its
review of the Site Application Plar, and supporting documents for
the proposed Solid Waste Management Facility in. Anson County,
North Carolina. These comments are prcvided :tr accordance with.
provisions of the Fish and Wildlife Coordination Act, as amended
(1-5 U.S.C. 651--667d) and Seczion 7 of t. a Endangered Species Act
as amendad. ,.,0 6._ 3. S._.C. 1531µ- �.A3 )
Based on' the results` afthe endangered ,pec es surveys, we corker.
that the proposed facility is not likely to adversely affect
Federally -listed endangered cr threatened species. Therefore,
the requirements of Section 7 of the Act have been satisfied.
However, obligations under Section 7 of the Act roust be
reconsidered if., (1) new, nf.ormation reveals impacts cf this
identified action that may affect listz : spec,;.es or. czitidal
Habitat in a manner not previously cans tiered; (2) this action
is subsequently mcdified in a manner which was not considered in
the document; or (3) a reefer species is listed or critical habitat
determined that may, be affected liy the ...identified ...action. .
The Service has interest in the. proposed landfill site due to
it's proximity to the pee Dee Naticnal gildlife Refuge (Refuge) .
In additon to the location of the propaved site, the Service is
concerned with the water quality of the creeks bordering the
site. Pinch Gut Creek flows into 6rowr creek,the main drainage
for the County, and eventually floes directly through the Refuge.
Water from Brown Creek is used to floed wildlife impoundments
within. the Refuge.
Because ct the previous alteration �,t toe proposed site b-v the
pine plantation, and the measeires taken to avoid and greserVe
buffer areas along Brown and Pinch Gait Creeks, the Service
believes that wetlands are not likely t� be adversely immaczed
physically by the facility. Efforts to have these aet.land
buffers managed as permanent ccnservatiun easements is
encouraged.
00: 47 T L6 = J.:)C 20cd 022,� ::Ntl Z ES2 Z ©L_EQL.L

The service offers tie,, follow .ng tec -ini.Ca1 assistance cosnmeests. on
issues noted during this review. Tne section in the site Plan
Application regarding the typo, quantity and source of wastes
indicates that the facility will be Lece.lvinq contaminated soils.
We recommend that than type, level anti quantities of contaminated.
soil that the facility is proposing to accept be included in the
environmental documant and made availiable for public reviewand
comment
The Service strongly recommends that: contaminant monitoring. of
the proposed facility include biota and sediments: in addition. to
the currently proposed plans to monitor surface water, ground
water, and leachate. Sediment and biota represent potential
contaminant sinks through adsorption (sediments) and
bioaccumulation (biota)m These media would be more
representativp_ in assessingth.e long --terms impacts > of the facility
than data provided only by groandwat<er and surface water quality
monitoring. Species'the:service recommends for monitoring
include mussels (e.g. E1112t.ic cod lanata;, turtles `m-g.
snapping turtle chelvd�7 a sermentina) , and fist., including
warmauth, bullheads; and suckers. `these biota and sediments
should be.-ca'liected t the surface water man�,tcring stat.io.ns
Pinch ... .Gut.. and Brown Creeks and, anal -_ed annua 'Iy. The first..
collections of these media shru„d ..occur rziLor. to .Iandf ilI
development to establish a baseline.
Finally, the service' advocates that . non --discharge alternatives
for di5pesa3 : of .reatedleachate be .rxorfleas ly evaluated because
of patenti.al adverse impacts �.he..discharc�e may lia�re. on E�irsci�::,,Caat
and Brown Creeks, and ultimately on the Pee Dee National Wildlige.
Refuge. if non -discharge alters+atiVas are not feasible, we 'would
appreciate the opportunity to review the Draft National Pollution
Discharge Elimination systam permi�- for ,surface water discharge.
......
Add . itionally, we request the -::�pportur<ity to _review the moft1torin.g......
portion of tha draft Construction and operations plan and the
draft permit+ for landfill
Tl operation. r'f S4� y F SS / ^MYn vY
T."La .k 9rlou fo bier 4;:pppc V�ednity o me,.,_Js and provide aA+IW ents on
the site Plan Application. We encourage your consideration cf
these camrument.s. la you have any questions, please contact either
i�aoiogists Kate Looney or Tom Augspurger of this office.
3'Mc:erely,
L.K. M-LkeGant-t
sure`visor

directly on the baseliner. leachate collection pipe{s) will be installed in the drainage layer to
collect and convey the leachate to the leachate sumps located along the deep end of the landfill.
lzachate collected in the sumps will be pumped out by submersible pugs placed in the leachate
sumps via the side slope risers. Pumped leachate will be transported to leacchate storage tanks
via a farce -main.
1_.eachate pumped from the system will be temporarily stored in the leachate storage
tank(s) before transported off -Site to the local POT W for. treatmentand disposal. The leachate
storage . tarok will. be "surroundedby concrete -walled secondary containment to contain, and
prevent release of the leachate should the tannic fail or leap.
An active landfill gas control system is proposed to prevent on -site accumulation gases
errerated in the landfill by decomposition of the waste. The landfill gas control system will also
.pressure exerted on the barA'ier .soil layer and the membrane bra the cap and control
odor. The system will consists' of gas extraction wells, collection headers and blower(s) to
evacuate the landfill gases. A flare will be installed to butte gases collected -
The proposed landfill design incoiporates stormwater and `sediment measures intended to
prevent accelerated soil erosion and off -site sedimentalicr, The final landfill surface will include
side slopes terraces at nominal 40 feet vertical intervals. The side slope terraces will intercept the
storrnwater runoff and discharge it to pipe drawn spouts. The pipe down spouts will discharge
into the perimeter ditch Storrnwater-collected in the perimeter ditches will be .diverted..to one of
the three sedimentation basins surrounding the landfill footprint for detention and discharge to
the streamrss in the site vicinity. The proposed perirter ditches and basins will be vegetated or
rip -rapped to minimize potential for erosion. Outflow from. the basins will be controlled by riser -
type outlets and discharged to a rip -rap apron to reduce flow yelocities and erosion potential.
1.2.4 Lear -hate Mana�er�nt
1.2.4.1 Leachate Collection S stern
The landfill has been divided into sixteen landfill cells separated by limed soil
ber[ns. The leachate generated in the cells will be collected by the leachate collection system and
discharged to a. sump. Each cell will be provided with a leachate surnp located near the
perimeter berme at the lower end of each cell. The proposed layout and details of the leachate
collection system are shown on Drawings No. F-2 and F-4 of the facility plan set. The
engineering basis of this design is given in Sections 2.1.3 and 2.2.1.1.
1-6

1.2.4.2 Leachate Collection Taraina e !Me
The proposed leachate collection layer will consist of. a I2-inchthick granular
layer with a miniar► m pe ility,of 0.1. crW= gr:.greater.. A.survey of the ,borrow sources in
the area was performed to identify. potential sources and the availability of borrow materials
nneting this criterion. A soil sample was obtained from one of the borrow sources (B.V.
Hendrick Gravel and Sand, Lilesville,.. North Carolina) .and submitted for laboratory gnddation
and perrrr-ability tests. "Test resents: indicate that: the pem=bility ef,t.h s material is expected to
exceed the design requirermnt.
The drainage layer will be placed directly on trip of the base liner
(georriernbrane). The proposed landfall design provides a m soil subgrade post-settlernent
,slope of 2% along the drainage.;, sand layer to ensure: flow of leachate. to, the leac=e collection
sumps at the lower ends ofthe:landfill.1botprint. The proposed design also includes.geosynthetic
drainage corraposite (geonet) as an -alternate to the granular drainage. layer.... .
1.2.4.3 "l ,P" Model AgW3y,,s and Collection system S�mg
L,eacirare flows were estimatedby rmdeling rain water balance. through the
landfill using the HELP Model (Section 2.2. 1. 11). Conditions during the initial waste placer Ent
operationsof a cell will generate maximum leachate due to accumulation of 100% of the
precipitation within the separation berm (Le.,, no runoff allowed) and infiltration of learchate flow
by the waste tWckness in place. A waste.thickness of five feet was utilized to model the _in ial .
operating conditions in each cell. The initial operating condition am conservatively assumed to
be the "Normal Operating Condition" forevaluating the proposed -design..
The in itrattion rnovernent (balance) across into, through and out of the landfill
was analyzed easing EPA's Hydrologic Evaluation -of Landfill Peffommce (HELP) cocxtputer
...gro.graasi, Version 3....( aectio.n;.2..2..1:.LI).. iand.ciimatolo.gical data for Charlotte, North
Carolina available in the, HELP database were utilized for dmr analyses. Analyses were performed
for the following three conditions
-
Initial Condition (T of waste in -place);
® hate Condition (waste placed to 60 ft., no cap); and
e Final Condition (waste to full Height and capped).
IIELP Model analyses results are sununarized on 'Tables 1 and 2 of Section 2.2.
Based on the HELP Model analyses, a peak daily leachate generation rate of 44 gpm is estimated
in the largest cell (2A) under Norz ml Operating Condition. Eased on the HELP analyses results
for these three conditions (bulleted above), peak daily and average monthly/daily leachate
generation rates were calculated for different stages (phases) of the landfill development.
1-7

NCDE regulations (15A NCAC 13B.164(b)(2)(A)].:.and Sxxbtitle D require
limiting the leachate head on the liner to one foot with an impinge. rat rate on.t:he drainage layer.
equal to the peak monthly precipitation rate. To evaluate the performance of the leachate'
collection system on top of the geomembrane, additional HELP analyses were performed with
the precipitation aniount. set to the " peak rre ahly rate". The historic monthly precipitation>data
(1938 to 1995) for the nearest location (Wadesboro, N.C.) was obtained from the U.S. Weather.
Bureau, National Climate Data Center hornepage an the "World -Wide -Web'. This precipitation
data was used to calcuiate ,men monthly. precipitation and the .standard deviation. The :value:
two standard deviation above the me (97 5%© confidence level) was used as. the "Peak Monthly
Precipitation lute' for the HELP analyses. A daily precipitation €ate calculated 'l'r€ m the peals
nionthly,rate (Weak Monthly Precipitationitate130) and specified for 365 days in the HELP input
to nnodel a steady-state precipitation condition. The results indicate that for the -proposed base
slope, the damage layer peiunability and t.he: collector pipe spacing,. the peak daily, head on the
liver will not exceed one foot as requited by the xIN .EHNR Subtatle: D regulations. .
1.2.4.4 Leachate Collection Piers
The proposed 6-inch-diameter (RDPE) leachate collection pipes at the typical
slope of one percent have an estimated flow capacity of about 350 gpm which is significantly
greater than the peak daily leachate generation rates estimated by water balance method (FIE1LP
analyses):
The leachate collection .system pip design includes cleanout, risers along the.
perimeter landfill berm to provide access for cleaning throughout the operating and post -closure
ire period of the facility: Location. of the cleart:raxt:risers :are . showrs:on Drawing No- F;4 of the
facility plan set, Section I.1;2. Details of clean out risers are shown on Drawing E-10 of the
engineering drawings, Section 2.5.
1.2.4.5 Leachate Collection Sumps and Paxrsps
The leachate collection pipes are designed to gravity discharge to leachate
collection sumps located at the perimeter of each cell. Leachate collected in the sumps will be
punted out via sideslope pump riser and conveyed via a leachate force main to 100,0W gallons
(nominal capacity) leachate holding tanks. From the holding tanks, the leachate will be trucked
off -site for disposal at the County wastewater treatn-&nt plant. In the future, Chambers may
elect to pursue direct discharge to the municipal sewer (available along U.S. route 74). The
sumps will be equipped with automated level and alarm sensor to automatically operate the
landfill sump pumps and indicate pump failure to the operator. Proposed layout and details of the
leachate sumps, sideslope riser, force main and, storage tanks are shown on Drawings No. E-11
and E-12, Section 2.5.
1-8

The icachate collection sumps have a base dirnension of about 15 feet by 15 feet
and a: storage height ofthreeand a half feet with 3 horizontal to 1 vertical sidesippes. Tlie
estimated: available "live" storage volurrz of each sump is approximtely 16,000 gallons. Each.
sunup in an active cell will be equipped with a 50 gpan (30 gpm if geonet is utilized) nominal
capacity submersible pump. For inactive (capped) cells, each suanp will be equipped with. a:.
15 gpin pump. The sunup and pump am designed to provide acceptable pun p. cycle of nes/starts
per day.
1.2.4.6 leachate Ford Main
_... ........
l eachate collected: in the collection sumps will: be pumped to a leachate storage
tank via a force -amain. The force-nmian will consist of SDR-21, high density polyethylene. pipes.
The force -amain pipes will be of 4-- or 6--inch-diameter. Calculations (Section 2.2), indicate that
the proposed pumps will.have adequate by capacity, discharge floe leachate from landfall
sumps to the leachate storage tanks via the force-nnain.
11.4.7 Le-achate Corntain-ment Eerraa
The proposed design includes perimeter beams and cell separation benans to
control and contain the leachate in. the: areas provided within:: the base liner. The sube-611`
separation berms wiIprevent. mixing of ft leachate horn adjacent cells .and act as-storanwater
separation berm prior to the develop =nt:or-construction of dieadjacent cells, Per NCDEHNR
requirement [15A NCAC 13B.1624(b)(2)(A)), the top of [he perimeter and .the cell separation
bermes are: designed to contain the voluan of leachate generated.by a.24-hour, 25-year storm:
1.2.4S L,eachate Storage and Disposal.
The leachate will be stored in a 100,000 gallon, ahove-ground, belted steel
tank(s) located on the southwest side of the faciiaty The storage tanks will be surrounded by 'a
concrete -walled secondary contain=nt to contain leachate if the tank should leak- The
calculated containment volunne within the concrete walls is designed to exceed the tank vokirne
by more than the 10%® required by the NCDEHNR regulations [15A NCAC
13E.1680(c)(2)(A)j.
The storage tanks will be equipped with a renting system and water level sensor
alamas to indicate high liquid level to the operator and to shut down the pumps in the sumps if
the tanks are full. Location, layout and details of the leachate storage tank are shown on
Drawing No. E-12 of the playa set.
1-9

d
LES ASS ITS, INC.
CONSULTING ENGIMERS
11 1 COMMCNWEALTH COURT, SUITE i 04, C CRY, NC 2751 1-4464
PHONE: i9191, 319-1 157 FAX; (919) 481-1 4,22
September 1, 1998
Project No. R98-632-696
Mr. Allen S. Davis
DEPARTMENT OF THE ARMY
W1L2N-1MC;T0NL DISTRICT, CORDS OF ENGENEERS
P.O. Box 1890
Wilmington, TIC 28402-1890
Response to August 10, 1998 Comment Letter
Concerning Analysis of Wetland Fill. Alternatives
Anson Count-J Solid:. Waste Management Facility
'-.ambers Development of Nonh Carolina, Inc.
Anson Count
y, North Carolina
Dear Mr. Davis:
On behalf of our client, .Chambers Development of North Carolina, Inc. (.Chambers), Almes
Associates, Inc. Consulting Engineers (ALMES), respectfully submits this letter in response to
your co=ent letter�1 dated August 10, 1998, regarding the analysis of wetland fill alternatives.
To expedite your review, the Corps of Engineers comments are presented. verbatim in bold type,
followed by the AilvlEs response.____. ......... ..... .........
CO ENT lk
Permits for work within wetlands or other aquatic sites are available only if the proposed
work is the least environmentally damaging, practicable alternative. Please furnish
information regarding any other alternatives, including upland alternatives, to the work
for which you have applied and provide justification that your selected plan is the least
damagp ng to water or wetiaand areas.
RESPONSE
Within the property, the location of the solid waste boundary has been defined in an attempt to
meet the location restrictions contained within the North Carolina Department of Environment
and Natural Resources (TIC DENR) Solid Waste Regulations, The regulations state that new
(1) Department of the Army, Wilmington Disuic% Corps of Engineers — Letter, Allen S. Davis to Brian Card, P.E., "Action I.D.
No. 199900592, dated August 10, 1998,

Mr. Allen S. Davis
Department of the Array, Corps of Engineers
September t, 1998
Page 2
municipal solid waste landfill (MSWLF) units must establish a minimurn;00-foot buffer
between the MSWLF unit and all property lines and a minimum 500-foot buffer between the
MSWLF unit and existing private residences and wells. In addition, the location of the solid
waste boundary is further restricted by the existence of the CSX railway and related right-of-way
along the southern boundary.
Due to the.requirernents for. landfill siting and construction established by SIC DENR; it is
increasingly difficult to site any new solid waste facility without encount�ring wetlands or
jurisdictional waterways. In particular, North Carolina is highly dissected and has a line network
of small intermittent tributaries, perennial streams and associated wetlands. In many cases of
new landfall siting, wetland avoidance is not possible, since a parcel of land for potential landfill
development must be sufficient in size, on the order of several hundred acres, to include the
MS`YVLF unit and its required buffers: soil borrow areas, and ancillary facilities.
A wetland delineation was conducted by Garrow & Associates in late 1991 and early 1992. The
purpose of the delineation was to identify all existing wetlands so that any potential wedand>
iripacts could be avoided.;._ The solid waste_ boundary w , designed to avoid the wetlands
delineated at that time and the Pernir:to Construct, including this design, was subrnitred.for
approval to the Solid;Waste Section of NC DEAR. however, some time following the design
and lavout of the landfill and the submittal to NC DEAR, the Corps, in a site survey on February
24, 1998, delineated additional areas along intermittent drainage channels that were deemed to be
jurisdictional. These subsequent findings by the Corps were within.the previously defined
landfill footprint::
Complete avoidance of jurisdictional wetlands, as defined recently by the Corps of Engineers,
has been evaluated. However, at this point, wetland avoidance by .relocation of the solid waste
...........
boundary is not feasible. The intermittent drainage channels (wetlands) being affected are of
marginal quality and the relocation of the solid waste boundary would impact higher quality and
more diverse wetlands within the property boundary. This does not appear to be an alternative,
as the permitting process for the currently designed facility is nearing its completion.
COMMENT B
It is necessary for you to have taken all appropriate and practical steps to reduce wedand
losses. Please show all that you have done, especially regarding development and
modification of playas and proposed construction techniques, to reduce impacts.
RESPONSE
Chambers has attempted to minimize wetland losses by developing the upland portions of the
property. NC DEN+R requires a minimum vertical separation distance of four feet between the
ALMES & ASSOCIATES, iNC. _
CONSULTING E G;NEERS R98-632-686
t1ALME5-RALEiGH1AA]FROBDocuments\Allied-6861Anscn Co. LF• R9M321Davis.letter.9-1-4s,doc

Mr. Ailey S. Davis
Department of the Army. Corps of Engineers
September 1, 1998
Page 3
post -settlement bottom elevation of the base liner system of a mSWLF unit and the seasonal high
groundwater table and bedrock. This requirement further restricts downgradient development.
In addition, Chambers has avoided any development within the 1 OD -year floodplain. Chambers.
has also taken steps to intentionally avoid: construction within higher quality wetlands such as the
shrub/scrub and forested wetlands along' Pinch Gut Creek and Brown Creeks.
Chambers will farther Minimize impact on remaining. higher. quality wetlands by constructing. and
operating atin tire° facili . e ..... .
p g tY in a manner that rruruir�es harm to:the aquatic enviroiiinenta In �ccordarice with:
the NC DENR regulations and modem landfill design practices, the proposed landfill design
incorporates the following containment: and environmental control cyst-ms:
Subtitle. D composite base liner system or equivalent;
leachate collection, control and conveyance systems;
=eachate storage facility;
® composite Subtitle D final cap system;
landfill gas collection and venting system;
siorirciviater; sedimentation and erosion managerr enr systerns; and
groundwater and surface .wester morutoring systems.
The above components are provided and designed to facilitate proper land -fill operation and provide
appropriate environmental protection. These coeitainment and environmental control measures will
provide extensive protection for the aquatic environment, prevent sediment accumulation,.and manage
runoff iron -acts to Brown and`Pinch k0ut Creeks and associated high quality wetlands.
COMMENT
The 1 OA, ;requires that appropriate and practical mitigation will be required for all
unavoidable adverse impacts remaining a ter all appropriate and practical minimizndon
has been employed. You have furnished a draft plan to mitigate for the projected,
unavoidable loss of waters and wetlands. You have been asked to submit the draft
mitigation plan to the (North Carolina Division of Water Quality for review and input as to
what mitigation will be required to satisfy state requirements. You are requested to advise
this office of all such state requirements.
RESPONSE
The proposed Anson County Solid Waste management Facility will result in the unavoidable fill
of approximately 1.6 acres of wetlands. As you are aware, Chambers proposes to offset the loss
of the 1.6 acres of wetlands by constructing an additional 3.3 acres of wetlands, at least twice as
much wetland habitat as that which will be lost as a result of landfill construction, in another area
of the property. In addition to providing additional surface area, it is anticipated that the
AUVEs s ,assocs,aTES, INC.
CONSULTING ENIGMEERS R99-632-686
1 ALi6E5-RALEIGH1AAiPROI\CocumcnaslAllied-U45%Anson Co. LF1R98-6321,Davis.lettrr.9-i-98.doe

Mr. Allen S. Davis
Depm-went of the Army, Corps of Engineers
September 1, 1998
Pace 4
replacement wetlands will provide a more diverse and higher quality wetland Habitat than what is
currently available. The proposed wetland mitigation site is located just sor-it -,of the ex
ist n
CSX railroad right-of-way on the western side of the property..: The proposed site will be tied
into the eastern edge of a large eNisting shrub/scrub wetland.within :the Brown: Creek drainage
area.
The draft mitigation plan'was submitted to Mr. John Dorrley of the North Carolina Divisi®n of
Water Quality on June 5, 1998. Mr. Domey has riot yet reviewed the: plan and has indicatedthat
He would notify Chambers and the Corps of Engineers of his comments regarding the draft
mitigation plan during the public comment period.
ALMES trusts that this information will satisfy yourneeds at this time, If you have any fizrther
questions, or require any additional information, please call. We thank you in advance for your
prompt attention to this matter.
Respectfully Submitted,
ALMESASSOCIATES" INC:
Daniel A. Maltese /
Wetland Specialist
DA1VI/HPZ
cc: Brian Carol, Chambers
Steve Roberts, Chambers
Ramona ©'Bryant, Smith Helms Mulliss &c Moore, L.L.P.
R98-632-686 File
ALMES & ASSOCIATES, INC.
CONSULTING ENGINEERS
11ALME5-RALE]CjH\, A[PRCJli]ocuments1Allied�861Anson Co, LFtR98-632Tavis. letter, 9-i-98.doc
R98-632.626

1 FROM
IVWWAM S. ALMES
ALMES & ASSCCIATES, INC
1 [phone]
SUITE 104
111 CCM'MCNWEALTH CT.
CARY NC 27511-4447
FKG REF 1: R98-632-6M
UPS Onl iretr Office 5.0:11 vuonspod 769
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